December | 2021 | Alabama Bank News

Compliance Q&A: Open-end Credit Card and Due Date Considerations

Breaking, Compliance Q&A, Publications

Question: For an open-end credit card account, can a due date on the monthly billing statement vary if the usual due date is a Sunday? Example: The due date is usually the 12th of every month. However, 9/12/21, is a Sunday, therefore, the billing ...Read More

Compliance Alliance: FRCA and Risk-based Pricing

Breaking, Compliance Q&A, Publications

QUESTION: The bank currently provides the risk-based pricing notice in accordance with model forms H-3 and H-4, under the FCRA and Regulation V, for loans secured and not secured by residential real estate, respectively. The bank does not employ a credit scoring model or ...Read More

Compliance Q&A: E-Sign Act and Notice to Customer

Breaking, Compliance Q&A, Publications

Question: Must the bank follow the E-Sign Act requirements if providing notice of nonpayment to a customer electronically? Answer: The commentary to § 229.33(h), clarifies that a notice can be provided by email or fax. However, only Regulation CC, Subpart B, requires conforming with ...Read More

Compliance Alliance: Returned Check Notice

Breaking, Compliance Q&A, Publications

Question: Is a bank required to notify customers of a deposited check being returned? Answer: Yes, Regulation CC, § 229.33(h), requires providing notice to a customer of a check being returned by midnight of the banking day following the banking day on which the ...Read More

Monthly Archive:: December 2021